The leading authority on causation is Athey v. Leonati, 1996 CanLII 183 (SCC), [1996] 3 S.C.R. 458. In that case, Athey, who had a history of back problems, was injured in two motor vehicle accidents in February and April 1991. In the fall of 1991, he had recovered to the extent that his doctor recommended he resume his regular exercise routine. While warming up in the gymnasium, he suffered a herniated disc.
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